What is a P2 Plan??

If you have been in the environmental business for a while, you are likely well-versed in the submission dates for the Federal Programs that occur each year [e.g. Air Emissions Inventory, Toxic Release Inventory (TRI). If you are a Texas native, then you know that we always go above and beyond to make Texas the best place on Earth. One of the ways we, Texans, take care of our home is through pollution prevention measures. The Waste Reduction Policy Act was adopted by the Texas Legislature in 1991, which enacted the requirement for Pollution Prevention Plans (P2 Plan).

Am I Subject to this P2 Plan?

If you are a Texas facility that falls under one of the following categories, you are required to develop and maintain a P2 Plan. This applicability criteria are identified pursuant to 30 TAC §335.473.

• Large Quantity Generator of Hazardous Waste;
• Small Quantity Generator of Hazardous Waste; or
• TRI Form R Reporter

Read on to learn how to comply.

When is the P2 Plan due?

Initial P2 Plan (Base Plan): Within 90 days of the first Annual Waste Summary or TRI Form R submissions

Annual Progress Report (APR): July 1 of each year

Executive Summary: July 1 of each year

Renewal P2 Plan: January 1 of the first year of the new plan (5 years after the Initial Plan).

How do I comply?

The P2 Plan comes in two separate parts: The Initial P2 Plan and the Annual Update. The overall goal of the plan is to identify areas of source reduction and waste minimization. In addition, the plan requires facilities to develop and execute projects to reduce pollution. Outside of developing a plan, submitting it to the Texas Commission on Environmental Quality (TCEQ), and maintaining an updated copy on-site, there are not many requirements around how to achieve the pollution prevention goals. The method of reducing pollution is facility-specific. The TCEQ has outlined seven steps to guide you through the process and provides examples for their expectations.

1. Identify your processes and wastes
2. Prioritize your wastes
3. Identify your options to reduce waste
4. Prioritize projects and set goals
5. Train employees on P2 awareness
6. Document the P2 Plan
7. Report results annually

The TCEQ developed detailed guidance around each of these steps in “A Guide to Pollution Prevention Planning”.  Although this document offers a great starting point, the process isn’t a walk in the park. It is expected that the facilities will review their individual waste streams in detail and develop ideas to reduce waste in every area of operations from process waste streams to lightbulb disposal. The waste reduction ideas will have to be both a significant reduction and technically and economically feasible to the facility. Although not required, it is expected that the waste reduction projects identified in the plan are executed. The APR is a progress report on each of these projects to reveal how well pollution is being reduced at a facility. Included with the submission of the APR is the Executive Summary, which requires a signature from the facility Responsible Official (RO). Keep in mind, there are no bare-minimums when it comes to these plans. The TCEQ has not provided hard and fast rules, but still has high expectations for these pollution prevention projects.

Why Should I Comply?

The plans are mandatory and failure to develop or maintain the plan results in violations, fines, and enforcement. If that’s not enough, the plans are beneficial to the Texas environment and your facility. When done well, P2 plans can be beneficial to various parties. And if TRI releases are reduced below the TRI reporting thresholds, you can graduate from the P2 program, which is the ultimate goal of the Pollution Prevention staff.

Where Can I Find Help?

The TCEQ has provided online and hardcopy guidance around developing the base P2 Plan and completing Annual Updates. The most useful is “A Guide to Pollution Prevention Planning” developed by the TCEQ. In addition, the Pollution Prevention and Education (PPE) staff is easily reached at the following places:

www.P2Plan.org
Technical Assistance Phone #: 512-239-3143

If none of this seems like your cup of tea, the ALL4’s Texas team is ready to tackle your environmental needs. If you have any questions, feel free to reach out to me at 281.937.7553 x304 or rhenn@all4inc.com.